aspects of the storage permit application for co2 storage ... · taqa to the dutch ministry of...

Energy Procedia 37 ( 2013 ) 6287– 6294

1876-6102 © 2013 The Authors. Published by Elsevier Ltd.Selection and/or peer-review under responsibility of GHGTdoi: 10.1016/j.egypro.2013.06.557

GHGT-11

Aspects of the storage permit application for CO2 Storage in the depleted gas field offshore the Netherlands

Andreas Koppa,b,*, Menno Rosa, Tom Jonkera, Wevers Jean-Pierrea,c, Chris Gittinsd, Willem-Jan Plugd

a ROAD, Maasvlakte CCS Project C.V., P.O. Box 133, 3100 AC Schiedam, The Netherlands b E.ON Gas Storage GmbH, Norbertstr. 85, 45131 Essen, Germany

c GDF SUEZ Global Energy, Grote Voort 291, 8041 BL Zwolle, The Netherlands d TAQA Energy BV, PO Box 11550, 2502AN, The Hague, The Netherlands

Abstract

developed by E.ON and GDF SUEZ. The project receives funding from the EU as one of six selected projects within the EEPR funding scheme, the Dutch Government, and the Global CCS Institute. The post-combustion capture unit

-fired Maasvlakte Power Plant 3 (MPP3) and will capture ca. 90% of the CO2 from approximately 25% of the flue gas. On average 1.1 million tonnes of CO2 per year will be compressed, transported via a 25km insulated pipeline to the P18-A platform operated by TAQA, and permanently stored offshore in the P18-4 depleted gas reservoir. In the five year demonstration period a total amount of 5 million tonnes CO2 is envisaged to be stored. The project will be the first of its kind and is intended to demonstrate the economic, regulatory, and technical feasibility of Carbon Capture and Storage in a safe and responsible manner to reduce carbon emissions to the atmosphere. This paper discusses selected aspects of the permit application for CO2 storage in the P18-4 reservoir, filed for by TAQA to the Dutch ministry of Economic Affairs, Agriculture and Innovation (EL&I). The European Commission has stated its positive opinion towards the Dutch ministry EL&I on the permit application and the draft storage permit [5]. Once a permit for CO2 storage is received, this project will be the first in Europe to hold a storage permit following a national implementation of the CCS-Directive 2009/31/EC [4]. © 2013 The Authors. Published by Elsevier Ltd. Selection and/or peer-review under responsibility of GHGT

* Corresponding author. Tel.: +49 201 94614 547; fax: +49 201 94614295 547. E-mail address: [email protected].

Available online at www.sciencedirect.com

© 2013 The Authors. Published by Elsevier Ltd.Selection and/or peer-review under responsibility of GHGT

6288 Andreas Kopp et al. / Energy Procedia 37 ( 2013 ) 6287– 6294

Keyword: CCS; storage permit; CO2; The Netherlands.

1. Implementation of the CCS-Directive into Dutch national law and application process

The application for a storage permit follows Dutch implementation of the EC CCS Directive 2009/31/EC. The national Dutch implementation includes several amendments to existing law. It is a literal translation of the Directive, no additional requirements have been added to the amendment. The Directive is transposed in the Dutch Mining Act, but also in regulations (Mining Decree and Mining Regulation). There is also other relevant legislation that needs to be considered and which is not covered by the CCS-Directive (like e.g. RCR , civil liability, EIA, etc.). Finally, the Dutch Government will develop additional CCS legislation in the future to ensure that CO2 can be stored in the Netherlands (regulations for infrastructure, abandonment requirements for platforms and wells, trans-boundary issues, etc.). The major steps and milestones that have been taken in the application process so far are outlined below:

Extensive discussion with the competent authorities to understand the application process and how to interpret regulation. TAQA filed the storage permit application to the Ministry of EL&I. Discussions with the official independent advisors of State (Sodm). Discussions with other independent advisors of State (TNO). Start of the term in which competitive applications can be submitted (91 days) English version of the permit application is submitted to the European Commission The Ministry issues a Dutch version of the draft storage permit Start of the term in which stakeholders and the public can submit their opinions on the draft

permit Start of the term (4 months) in which the EC can give their opinion on the draft permit End of the term in which competitive applications can be submitted Ministry of EL&I receives opinion of EC Waiting for preliminary storage permit

In total, an applicant might need to allow for about a year from initial submission to receiving a (revocable) storage permit. For an irrevocable permit this time period might become substantially longer. The timeframe can of course vary and will hopefully reduce after some experience is made by all parties involved. The application document consist of an overarching master document, and supplementing documents, i.e. a risk management plan, a plan for corrective measures, a provisional closure plan, and a monitoring plan. These documents will be updated six months before start of operation.

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2. Feasibility study of the P18-4 depleted gas field

A comprehensive study on the feasibility of the P18-4 storage field has been conducted before filing the storage permit application which took approximately 2-3 years. This is a relatively short period of time (compared to the exploration and feasibility study work required for a saline aquifer), and is possible because of the broad knowledge base and experience already gathered during exploration and production of this gas field over the last 20 years. Besides the work done by ROAD and TAQA personnel, a considerable part of the study was performed by the Dutch national project on CCS (CATO-2), which is supported by the Dutch government and involves universities, research institutes, and private companies. A separate paper is presented on this subject at the GHGT-11 conference [2].

3. Storage Location and Storage Complex

In the permit application for a storage permit, the storage location (or site) and the storage complex need to be defined as specified in Article 3 of [4]. The definitions are given below and the interpretation for P18-4 is described. The definitions are supplemented with a more detailed characterization and definition in the application document. However, for the scope of this document, the following definitions should be sufficient.

The storage site consists of

the geological formation, in this case the P18-4 reservoir which is made up of the Hardegsen, Upper Detfurth, Lower Detfurth, and Volpriehausen rock layers (refer to Fig. 2). The reservoir is bordered and sealed by faults on all sides (see Fig. 1), the original production well, to become the injection well, from the well bottom to the well head, the injection facility, in this case the well head located on the P18-A platform, the control valve

and the measuring devices on the well. The storage complex consists of

the storage site, all geological layers above the storage reservoir up to the base of the Chalk Group, consisting of

the Upper Germanic Triassic Group, Altena Group, Schieland Group, Rijnland Group, and aquifer intervals Rijn/Rijswijk sandstone, Holland Greensand, and Texel Greensand, the formations below the storage reservoir, consisting of Rogenstein and Main Claystone, the fault zones around reservoir P18-4, the P15-9 reservoir, from which the P18-4 storage reservoir is separated by a fault zone.

In the storage complex the P15-9 reservoir is included because it directly neighbours the P18-4

reservoir separated by a fault with smaller vertical movement as compared to the other fault offsets. The -4 possibly partially borders here on similar

Triassic reservoir rock of reservoir P15-9. This is called reservoir juxtaposition. The thickness of the reservoir (approx. 200 m) is approximately equal to the fault displacement (approx. 170 230 m). On the basis of the seismic research, there is a maximum juxtaposition of around 30 m on the northwest side of the fault between P18-4 and P15-9, while on the southeast side of this fault there is no juxtaposition. In this case, a juxtaposition would affect the top reservoir zone of P18-4 (Hardegsen, with high permeability, 207 mD) and the lowest reservoir zone (Lower Volpriehausen, with extremely low permeability, <0.1 mD) of P15-9. However, there are several good reasons to assume that the fault is sealing, i.e. different gas compositions in both reservoirs, most probably a presence of a gas-tight cataclastic fault gouge [3],


strong assumption of no connection during gas production based on pressure measurements, different GWC (gas water contact) in both reservoirs. Since a connection cannot be absolutely excluded, reservoir P15-9 is part of the complex. If CO2 would unexpectedly migrate to P15-9, this would most probably happen at very small rates (due to extremely low permeability in the Lower Volpriehausen) and most probably CO2 would be stored permanently in P15-9 then (since the very same caprock as in P18-4 ispresent there).

For the P18-4 the situation is as follows:

Fig. 1: 3D view of the top of the P18 fields. Faults are shown in grey, well traces are shown in red.


4. Financial Security

Financial security in respect of the CO2 stored in the storage site has to be established by the responsibleentity which receives the storage permit. According to the requirements of Artcile 19 of the CCS Directive, the financial security must ensure that all obligations arising under the storage permit,including closure and post-closure requirements, can be met. The draft storage permit for ROAD requiresthat the financial security covers the following activities:

Regular monitoring costs over the lifetime of the permit (assumed is 9 years). The total amount decreases with remaining lifetime of the permit before handover of responsibility. Contingency monitoring costs mainly based on estimates for additional 3D-seismic surveys. The

total amount remains constant, since it can be required at every time.

Fig. 2: Left: Seismic cross-section through the P18 fields, displaying the reservoir interval (below the Altena group), the mainbounding faults to the reservoirs (bold lines), the main stratigraphic units in the overburden and the faults in the overburden (dashed). A map view of the P18 fields is shown in the upper right corner, with the position of the seismic cross-section indicated.Right: Stratigraphy and logs (GR and sonic) of the reservoir interval and overburden of the P18 fields, with aquifers and sealsindicated


Costs for corrective measures. The most important corrective measures are additional well abandonment costs (CO2-proof abandonment) and well repairs during the injection period. Regular (CO2-proof) well abandonment costs. Platform abandonment costs. However, according to other Dutch mining legislation, an operator

already needs to provide a security to ensure proper abandonment. Abandonment costs for the adjacent P15-9 reservoir wells including an already suspended well

in P15-9 (not shown in Fig. 1). A financial contribution must be handed over to the competent authority in order to complete the

handover of responsibilities. Here, we have assumed e.g. seabed monitoring (pockmark surveys) for 20 years. Financial security has to be put in place to buy ETS credits in case there is leakage. A calculation

is presented to estimate the maximum leakage rate for a suggested period. This rate is multiplied by an estimated emission certificate price. Finally, a contingency of 20% is added.

Consequently, the level of security (adjusted with time as agreed with EL&I and following advice from EC) is based on expert estimates of the costs of the activities above. Such cost estimates were made for regular monitoring, contingency monitoring (in case of irregularities), corrective measures, decommissioning costs for injection and monitoring wells and all existing wells that might eventually come into contact with migrating CO2, if any.

financial security or any other equivalentGuidance Documents give a (non-limited) summary of financial instruments to cover the financial security, for example: balance sheet, parental guarantee, funds, insurance, or bank guarantee. The financial security must be established before injection starts (for the ROAD-project this is in 2015). The eventual instrument to set the financial security will be set 6 months before first injection the latest.

5. Corrective measures

A consequent and robust risk assessment is the foundation for the plan for corrective measures (and for the provisional closure plan, and for the monitoring plan). In Article 3 of the EC-CCS-Directive [4], corrective measures are defined and get further explained in guidance documents 2 on the implementation of the EC-CCS-Directive [1] (page 128).

The monitoring plan specifies triggers before using corrective measures, which means that they become operational in case of significant irregularities. Article 29a of the Dutch Mining Decree defines significant irregularity as an irregularity in the injection or storage activities or in the condition of the storage complex itself that causes the risk of leakage or poses a risk to the environment or to public health. To put the risk of leakages into context here, the EC confirms in their opinion [5] relating to the draft permit, that the scientific advice provided to the Dutch authorities comes to the conclusion that the risk of leakage is

negligible and that there is no significant environmental or health risk .


Significant irregularities can be grouped into the following categories:

CO2 migrates outside the storage site or leaks from the storage complex, seismic activity caused by the storage, damage to the well or deterioration of the sealing layers and material, failure of the monitoring system or conceptual failure of the monitoring system setup, entire system functioning differently than expected.

Likewise, the different types of corrective measures can grouped into:

Expansion of monitoring research: As specified in the monitoring plan, which is part of permit application, additional monitoring takes place, Adjusting operational parameters: The injection pressure and/or injection rate can be adjusted to

determine whether this achieves a regular situation again. Causes for irregular behaviour need to be investigated. Halting injection: If migration is occurring (or leakage from the storage complex) and it cannot

be fixed, the injection can be halted temporarily. This makes it possible, for example, to examine the well and possibly repair it. If a situation arises that causes damage to the environment and/or health, the injection must be ceased entirely and the wells must be sealed. The same applies to possible problems on the platform. Extreme circumstances: Under extreme circumstances (for example, damage to the well from a

terrorist attack), it can be necessary to drill a new well.

For all the undesirable events described above, corrective measures will be taken to prevent the possible consequences described in the risk management plan. The overview in Table 1 indicates which corrective measures can be taken to prevent which consequence resulting from specific events.

Table 1: Overview of the relationship between events, consequences, and corrective measures.

Event Consequence Corrective measure (in addition to communication, informing the competent authorities and stakeholders, etc.)

1 CO2 outside storage complex/site CO2 from well to overlying layers CO2 escaping outside reservoir into subsoil Additional monitoring well cementation

Repair cementation CO2 from well to biosphere CO2 escaping into biosphere Additional monitoring well

Repair cementation CO2 from reservoir to biosphere CO2 escaping into biosphere Additional monitoring

Stop injection CO2 from reservoir to P15-9 CO2 escaping through fault zone to P15-9 Monitoring P15-9

Measures P15-9 2 Seismic activity caused by the storage Reactivation fault zones Integrity of subsoil affected Additional monitoring

Stop injection 3 Damage Damage to the well Function of well restricted Repair well Deterioration reservoir / cover layer (mechanical, chemical or temperature effects)

Integrity of subsoil affected Additional monitoring Stop injection

4 Monitoring Failure of monitoring system No insight into injection process Stop injection

Adapt monitoring Conceptual failure of monitoring No insight into injection process Stop injection


system Adapt monitoring 5 Entire system functioning differently than expected Restricted injectivity Less CO2 can be stored than foreseen Adapt pressure and temperature

Adapt monitoring Unexpected behaviour of CO2 in well or reservoir

Unpredictability of injection Stop injection Adapt pressure and temperature Adapt monitoring

In case of any event as described above, the appropriate authorities need to be informed immediately

and corrective measures need subsequently be put into action. The effect needs to be monitored and reported to the appropriate authorities.

The plan of corrective measures must be ready-to-use, and moreover aims at early warning and early

intervention to prevent the situation from deteriorating and thus reducing the risk. Finally, the corrective measures itself need to be carefully monitored to check whether they have the intended effect.

Summarizing, as by the Environmental Impact Assessment studies for the capture, transport and storage of CO2 concluded against the background of other activities and natural processes in the area, the adverse impacts are overall negligible .

Acknowledgements

This application for a CO2 storage permit involved a great number of experts from TAQA, E.ON, GDF Suez, Delft University of Technology, Schlumberger, Panterra and TNO. The ROAD project is co-financed by the European Commission within the framework of the European Energy Programme for Recovery (EEPR), the Government of the Netherlands and the Global CCS Institute.

References

[1] European Communities, Implementation of Directive 2009/31/EC on the Geological Storage of Carbon Dioxide, Guidance Documents 1 to 4, 2011.

[2] Arts RJ, Hofstee C, Vandeweijer VP, Pluymaekers MPD, Loeve D, Kopp A, Plug WJ. CO2 storage into the depleted P18-4 gas field offshore the Netherlands (the ROAD project), Energy Procedia, 2012.

[3] Nieuwland, D. A. Fault Seal Prediction in Sandstone Reservoirs - A quantitative and calibrated geomechanical method, 3rd International Conference on Fault and Top Seals - From Characterization to Modelling, Montpellier, France 1-3 October, 2012.

[4] European Commission, Directive 2009/31/EC of the European Parliament and of the council of 23 April 2009 on the geological storage of carbon dioxide, http://eur-lex.europa.eu, 2009.

[5] European Commission, Commission opinion of 28.2.2012 relating to the draft permit for the permanent storage of carbon dioxide in block section P18-4 of block section P18a of the Dutch continental shelf, in accordance with Article 10(1) of Directive 2009/31/EC of 23 April 2009 on the geological storage of carbon dioxide, http://ec.europa.eu , 2012.